Submissions

CFA submitted a follow‑up letter to the Minister of Agriculture and Agri‑Food regarding proposed amendments to the Plant Breeders’ Rights (PBR) Regulations, reinforcing its earlier submission from October 2025.

Key points highlighted by CFA:

– CFA supports the proposed amendments, which aim to strengthen Canada’s Plant Breeders’ Rights framework and encourage long‑term investment in plant breeding innovation.
– The organization recognized that stronger and more predictable PBR protections can help improve access to new crop varieties, enhance competitiveness, and bolster the resilience of Canada’s farm sector.
– Alignment with international standards, including those of UPOV (International Union for the Protection of New Varieties of Plants), was identified as an added benefit.

CFA’s core position and recommendations:

– Farmers’ privilege must remain broadly accessible, allowing producers to save and reuse seed on‑farm.
– Any future narrowing of farmers’ privilege should only occur with clear producer support and meaningful consultation.
– CFA believes the current amendments strike a reasonable balance between the interests of producers and plant breeders.
– The federation encouraged government to advance the amendments, as written, to Canada Gazette, Part II, stressing that regulatory certainty will benefit farmers and the broader sector.

CFA submitted a response to the federal Public Consultation on the Future Uses of the Pickering Lands, raising serious concerns about the permanent loss of prime farmland in one of Canada’s fastest‑growing regions.

Key points highlighted by CFA:

– Farmland loss is accelerating across Canada, with over 5 million hectares lost since 2001, much of it near major urban centres where land is most productive and vital for local food supply.
– The Pickering Lands include high‑quality Class 1 soil, representing less than 0.5% of Canada’s total land base, with about 87% currently leased and actively farmed.
– These lands are a rare, contiguous block of prime farmland, strategically located near Canada’s largest urban market, supporting short supply chains, lower emissions, and stronger regional food security.
– CFA emphasized that farmland is a finite, irreplaceable resource and that decisions made now will affect food production for generations.

CFA’s main recommendations included:

– The federal government should establish a mandatory Agricultural Impact Assessment (AIA) for all major federal land‑use decisions, similar to Ontario’s approach.
– An AIA would ensure agricultural impacts are fully considered alongside environmental reviews.
– It would assess cumulative farmland loss, impacts on food security, climate goals, and rural economies.

CFA submitted a joint submission with organizations from across Canada’s food supply chain, calling on the federal government to treat farming and food production as a core national priority—on par with energy and supply‑chain security. If food security is to be a national priority, the foundation of that is strong, profitable farms.

The letter urged long‑term investment to boost farm productivity, protect farmland and soils, stabilize access to key inputs (like seed, fertilizer, crop protection, energy, and animal health tools), and speed up access to new technologies. It emphasized the need for predictable regulations, fair access to capital, and policies that support innovation rather than add costs.

The document also highlights the importance of value‑added processing in Canada, better transportation and trade infrastructure, and labour solutions to keep farms and processors running.

It recommends a whole‑of‑government approach that removes barriers to growth, strengthens domestic production, and keeps Canadian food affordable, all while positioning farmers to compete and succeed at home and globally.

CFA submitted its comments on the Part I consultation on the Order Providing for Reliance on Decisions of, or Documents Produced by, Foreign Regulatory Authorities in Respect of Certain Drugs.

The letter urged Health Canada to modernize regulations so farmers and veterinarians can access veterinary medicines and animal health tools more quickly. In the submission, CFA supports a new “reliance” approach that would allow Canada to approve products already authorized in trusted countries like the U.S., EU, and Australia.

CFA stressed that timely access to vaccines, treatments, and other animal health products is essential for animal welfare, disease prevention, responsible antimicrobial use, and farm profitability.

The submission calls for the framework to go further, by including generic drugs, addressing products that are approved but unavailable, and eventually expanding beyond pharmaceuticals, so Canadian livestock producers are not left with fewer options than their global competitors.

CFA submitted a joint letter with farm groups from across Canada, warning that recent closures of federal agriculture research stations risk weakening the science system that farmers rely on to stay productive and competitive.

The letter noted that public research plays a critical role in developing region‑specific crop varieties, livestock and meat science, disease management, food safety, and long‑term agronomic trials—work that cannot easily be replaced by the private sector.

The letter urges the federal government to slow down implementation, protect ongoing research and breeding programs, and work directly with industry to ensure critical research capacity, expertise, and infrastructure are not lost.

Strong, stable public agricultural research is essential to farm productivity, innovation, food security, and Canada’s ability to compete in global markets.

On February 27th, CFA made its submission to the Horizontal Red Tape Reviews consultation.

In the submission, the CFA stresses that excessive, overlapping, and unpredictable rules are slowing down farm projects, raising costs, and making it harder for producers to stay competitive.

The CFA’s recommendations focus on five main areas:
– Project Reviews: Streamline approvals for on‑farm and agri‑food projects by reducing duplication among federal departments and setting clear, predictable timelines.
Getting Products to Market: Speed up access to essential farm inputs, such as feeds, veterinary products, pest control tools, by recognizing trusted international approvals and improving transparency in regulatory decisions.
– Reducing Administrative Burden: Eliminate unnecessary reporting, fix impractical rules like bulk fertilizer labelling, and modernize outdated legislation.
– Trade & Border Efficiency: Harmonize rules across provinces and international partners, strengthen export processes, and modernize border systems to keep Canadian products moving.
– Better Service Delivery: Improve consistency, communication, and turnaround times for inspections, approvals, and regulatory processes.

CFA argues that smarter, more efficient regulation will free up time and resources for farmers, supporting productivity, competitiveness, and a stronger Canadian food system.

Budget 2025 introduced immediate expensing for manufacturing and processing buildings, recognizing the importance of encouraging capital investment in critical production infrastructure. Aligning agricultural building expensing rules with the manufacturing and processing framework would ensure consistent treatment across core production sectors and reinforce Canada’s broader economic objectives under Budget 2025, including the recognition of agriculture as a strategic sector.

Furthermore, extending this tax provision to agricultural buildings would represent a logical and necessary next step to the Prime Minister’s January 26th announcement introducing immediate expensing for greenhouse buildings. Allowing producers to fully write off the cost of agricultural buildings acquired on or after November 4, 2025, and available for use before 2030, would provide critical support at a time when producers face rising capital costs and increasing pressures to expand production and diversify markets at the domestic and international level.

Agricultural buildings—including barns, storage facilities, livestock housing, and controlled‑environment production structures—form the backbone of Canada’s food production capacity. Removing tax‑related barriers to investment will enable producers to modernize operations, adopt innovative technologies, and scale production to meet growing domestic and export demand. Extending immediate expensing to all agricultural buildings would also advance national objectives related to food sovereignty, food security, and affordability.

Canada’s farmers remain heavily dependent on imported phosphorus fertilizers, leaving the sector vulnerable to unpredictable global forces. International market volatility, geopolitical tensions, transportation disruptions, and concentrated supply sources have all contributed to cost instability and supply uncertainty for producers. The risks associated with this reliance were underscored in recent years, when global fertilizer markets experienced significant disruptions—placing both producers and consumers at greater economic risk.

CFA encourages the Government of Canada to prioritize strategic investments, innovation, and regulatory pathways that enable the responsible development of domestic phosphorus production. Strengthening the availability of critical agricultural inputs aligns with national objectives for economic resilience, food security, and the sustainable growth of our sector.

Organizations throughout the food value supply chain have jointly written to the federal Agriculture Minister expressing deep concern over recent AAFC research station closures and cuts to public research capacity. The letter warns that these reductions threaten the productivity, competitiveness, and long‑term resilience of Canadian agriculture by disrupting essential research that cannot be replicated by the private sector, especially breeding programs, long‑term agronomy trials, disease screening, meat quality research, food safety work, and regionally adapted crop development.

The groups emphasize that losing research sites risks multi‑year delays in seed and variety development, the breakdown of long‑term datasets, and the erosion of highly specialized livestock, meat science, and environmental research infrastructure. They also note that industry partners were not adequately consulted before these decisions were made.

To prevent long-term damage, the organizations urge AAFC to delay implementation timelines, establish a clear transition framework to protect core research functions, and create a formal industry advisory committee to guide the process.

On February 13th, CFA delivered its submission to the Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities study on the impacts of Temporary Foreign Workers (TFW) on the labour market.

The submission emphasized that agriculture faces chronic, structural labour shortages, with tens of thousands of unfilled positions that domestic recruitment alone cannot meet.

In rural areas TFWs do not displace Canadian workers or suppress wages. Instead, they provide essential labour that sustains farm productivity, stabilizes local economies, and protects national food security. Evidence shows that TFWs help maintain billions in economic activity across key agricultural sectors.

CFA noted that employers face significant costs to participate in the program—covering transportation, housing, insurance, and regulatory compliance—reinforcing that TFWs complement, rather than replace, the domestic workforce. The organization stresses the need for a long‑term, reliable labour strategy that supports both seasonal and year‑round operations.

To strengthen Canada’s food system, the CFA recommended to:
– Maintain the current agriculture streams within the TFWP, including the Seasonal Agricultural Worker Program;
– Reinstate and make permanent the Agri‑Food Pilot to create pathways for experienced, non‑seasonal TFWs in critical industries.

On January 30th, CFA made a submission to the HUMA Committee as it studies the definition of “work” and the future of Section 107 of the Canada Labour Code. This section is an important tool the federal government can use to help prevent or resolve major labour disputes, especially in rail and port transportation, which farmers rely on heavily.

CFA stressed in the submission that when transportation workers strike or experience lockouts, farmers feel the impact immediately through:
– Higher interest costs due to relying on operating credit
– Demurrage fees and vessel delays
– Lost international market share
– Spoilage of perishable goods

CFA warned that removing Section 107, which has been proposed via Bill C-247, would greatly weaken Canada’s ability to prevent supply chain disruptions, potentially affecting both farm profitability and national food security.

CFA’s high-level recommendation included:
– Launch consultations with affected industries to address root causes of recurring labour disputes.
– Modernize dispute‑resolution processes, building on the 2025 Industrial Inquiry Commission’s recommendations—especially creating a Special Mediator with enhanced powers to ensure good‑faith bargaining.
– Amend Section 87.4(1) of the Labour Code by removing the word “immediate” so the CIRB can act when disruptions threaten essential goods like propane, diesel, or agricultural inputs.

In the submission, CFA highlighted several structural issues in India’s agricultural system that could limit benefits for Canadian exporters and impede market access regardless of tariffs:
– High tariffs and non‑tariff barriers on many agri‑food products
– Strong government intervention, such as price supports and export controls
– Unpredictable policy shifts affecting import demand
– Regulatory differences in inspection, certification, and SPS measures

It noted that while India is the world’s largest consumer of pulses, Canada faces 10–44% tariffs on key pulse crops, and market access to India has historically been disrupted by sudden restriction or administrative hurdles.

CFA urged the federal government to take a pragmatic, risk‑informed approach to any CEPA with India by:
– Prioritizing risk management and supply chain resilience
– Fully protecting sensitive agricultural sectors
– Strengthening SPS and biosecurity safeguards
– Ensuring enforceable commitments and fair dispute settlement
– Maintaining close engagement with farmers throughout negotiations